Attachment C - Consultations

EPA ICR NO. 2330.05 OMB CONTROL NO. 2070-0179

Attachment C

Consultation Questions for ICR: Pesticide Registration Fees Program

(1) Publicly Available Data

1. Is the data that the Agency seeks available from any public source, or already collected by another office at EPA or by another agency?

2. If yes, where can you find the data?
   (Does your answer indicate a true duplication, or does the input indicate that certain data elements are available, but that they do not meet our data needs very well?)

(2) Frequency of Collection

Can the Agency collect the information less frequently and still produce the same outcome?

(3) Clarity of Instructions

1. The ICR is intended to require that respondents provide certain data so that the Agency can utilize them.

2. Based on the instructions (regulations, PR Notices, etc.), is it clear what you are required to do, and how to submit such data? If not, what suggestions do you have to clarify the instructions?

3. Do you understand that you are required to maintain records?

4. Considering that there is no required submission format, is it difficult to submit information in ways that are clear, logical, and easy to complete?

5. Are there forms associated with this process? Do you use them? Are they clear, logical, and easy to complete?

(4) Burden and Costs

1. Are the labor rates accurate?

2. The Agency assumes there is no capital cost associated with this activity. Is that correct?

3. Bearing in mind that the burden and cost estimates include only burden hours and costs associated with the administrative materials involved with this ICR, e.g., the ICR does not include estimated burden hours and costs for conducting studies, are the estimated burden hours and labor rates accurate? If you provide burden and cost estimates that are substantially different from EPA’s, please provide an explanation of how you arrived at your estimates.

4. Are there other costs that should be accounted for that may have been missed?

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